CIPHR webinar – Building a case for electronic right to work checks

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Cathryn: Hello, and welcome to today’s webinar “Right to work checks building a case for electronic validation.” If you don’t know CIPHR we’re a leading UK developer of HR recruitment and learning software that helps organizations to attract, engage, and retain their workforces more effectively. We’re proud to have TrustID on board as one of our CIPHR connect partners. Their cloud, desktop, and mobile solutions make it quick, easy and effective to electronically check ID documents.

My name is Cathryn Newbery, and I’m CIPHR’s content marketing editor. I’m joined today by Tony Machin, TrustID CEO. Welcome, Tony, it’s great to have you with us today.

Tony: Thanks, Cathryn. It’s good to be here.

Cathryn: Okay, here’s the agenda for today. The webinar should last around 45 minutes with about 30 minutes from us and then time at the end to answer your questions. Do send in your questions, comments, and queries using the box that you can see on the screen at any time and we’ll answer them as best we can.

If you miss anything or have to leave the broadcast early, don’t worry. Everyone who’s registered will receive a link shortly after this broadcast ends to an on-demand version that you can watch at any time or share with your colleagues if you think they’ll be interested.

Now, I’m going to hand over it to Tony to tell you more about TrustID and give you an overview of right-to-work legislation.

Tony: Thanks, Cathryn. So I’ll say just a few words about TrustID and then we’ll get into the meat of the topic. So we’re specialists in identity document validation. And you can see we have a broad spectrum of customers across the public and private sector. And we support right-to-work, right to rent, right-to-study, KYC AML security and counter fraud checks.

We do that on a number of platforms, that can be from desktops, scanners, all the way through to mobile or cloud-based solutions. And we see hundreds of fakes regularly and we also support our own in-house help desk team manned by ex-Border Force and can often give you a faster response time than the home office. 

So getting into the real meat of the subject which is obviously the right-to-work. I don’t propose to spend too much time talking through something that I hope most people on listening to this will know something about and that is obviously the framework of the legislation. But really just for completeness, you’ll understand that the Immigration, Asylum and Nationality Acts to 2006 forms the basis of all right-to-work legislation.

What a lot of people don’t realize or have missed is actually the update to the Immigration Act in 2016. And in essence that really raised the bar in terms of putting pressure on organizations to actually comply with right-to-work, and brought in criminal prosecution, for example, and changed the fining structure. In terms of what the legislation requires again, I hope most people understand this in terms of the age requirements and you must be employed. 

What sometimes I get asked about well, who is an employee? And whilst that seems like a fairly obvious question, when you get around permanent, temp umbrella type companies and main contractors and subcontractors, then sometimes there’s a little bit of confusion around that. So my advice has always generally be very clear as to where the responsibility lies.

And there has been a couple of cases, for example, in the construction sector where main contractors has brought subcontractors on thinking that subcontractor clearly has the obligation to do the right-to-work check. But actually, the subcontractor has also fallen foul. Clearly make sure all checks are carried out before the employment commences and again may be a statement of the blindingly obvious but some organizations seemingly fail to do that.

Cathryn: Thanks, Tony. We’re just gonna dive into our first poll now which is around how you are currently checking right-to-work eligibility. You should see some multiple choice options on your screens now. Please select as many as apply to how you’re currently checking identity documents. Whether that’s a visual check, comparing them with an online database, using software based in your office, or using software that you can access remotely.

And Tony, what do you expect most people will be using at the moment?

Tony: I would suspect most people will be clicking the top one.

Cathryn: Okay, great and I’m just gonna close the poll now and exactly that your predictions come true. So 99% of our attendees who voted say that they are visually checking identity documents, so that is a huge proportion of you. Just 7% of comparing documents with an online database, 4% are using software that they can access remotely, and 1% are using software-based in their office.

And so that means your prediction came true Tony, but you’re surprised by how high that percentage is?

Tony: Not at all, I spend all of my time going out meeting businesses. And obviously, we only get called in just when people have this event or interested in technology to help them. And nobody, we’re not replacing anybody else we’re actually just improving their current process which is looking and photocopying documents. So I’m not surprised by that outcome at all.

Cathryn: Okay, thanks, for doing that poll with us so Tony’s gonna move on to the rest the presentation now.

Tony: Okay, so let’s move on now on to what we’ve just talked about on the poll actually checking your documents. And again this should be clearly obvious to most people, but in terms of what you need to check, you need to see the originals.

I think the second bullet point again is one where there can be some confusion. Because the right-to-work legislation does say or the guidance does say that actually, you can do an interview with somebody via video link. What you need to read though, is still have to have the original document in possession by the checker. So while she may be talking to the person over video link, you must have the physical document and seen the original document. So I think people who think they can do all the right-to-work checks remotely both the document and the person that is actually incorrect.

And clearly everything needs to be consistent and the person needs to look like the individual. We do see a lot of imposters where actually somebody is come in with a document that might be from a network of, I don’t know, organized criminal activity or from family and friends. And, of course, people doing the checks often forget to do the fairly basic thing which is to make sure the document does look like the person who’s presenting it. 

Clearly, if there’s any expiry dates or permits, restrictions you need to make sure you check those and take clear copies and then obviously sign and date them. And that is the current requirement that everybody should be doing. And as we just seen from the poll 99% of people are doing that looking at it, putting on a copier or taking a photograph of it and then signing it.

So in terms of statutory defense, which those who don’t understand that term. Statutory defense is what the immigration enforcement teams will be looking at to see whether you’ve done enough to make sure you don’t get fined or have criminal prosecution. So as long as you’ve done six things which again, I won’t spend time on in detail, then you’re a good chance that you’ll get your statutory defense. And only the immigration enforcement team can decide that. It is a judgment. At the end of the day, they are judging whether you have done enough to make sure that actually, you know, you’re not liable for a fine.

And you’ll notice on two and three where it says documents reasonably refer to an employee and documents look reasonably genuine. And that is where judgment comes in. So I get asked a lot of questions about how you know, I’m supposed to photocopy it? But the little legislation and the right-to-work guidance says you do have to make some effort to check if the document is genuine. And that again is a very, very broad spectrum of interpretation.

Clearly, if there’s a photograph in the passport that has clearly been cut out and replaced and it’s done badly, most people should understand that. But some fake documents are reasonably sophisticated and they will make a judgement as to how hard and how much effort you’ve put into checking that.

Now, this slide is actually from the immigration team. I know the immigration, head of policy at the immigration enforcement. And I asked him you know, “What are the things that you find most of the time when you and your teams go around and visit businesses?” And this is the slide that came back, all these the points that came back from him.

Clearly, there is more use of fraudulent and counterfeit documents particularly European ones than probably people realize. There’s a clear lack of awareness around identity fraud being used for illegal working. And too many people are just saying, “Well, it looks like a passport, therefore, it must be a passport and you know what? I’m gonna photocopy it.”

And supporting that they generally think a lot of organizations don’t put enough time and effort and can give evidence of any support, any training for HR teams around what they’ve done. And that often results always is point out of a failure of management to make sure that actually right-to-work checks are carried out properly.

One thing that I find bizarre but again is out there as evidence. Some organizations believe just taking a National Insurance number is a proof of right-to-work when it isn’t. Clearly, it has to be supported with some other evidence around the person’s identity. I think the outcomes turn up terms of other things they do find it a little bit strange that you know, the lack of effort in some instances around right-to-work clearly allows offenders to obtain access to other parts of business. And we’ll come back to maybe internal fraud issues later on.

I’ve already mentioned the oversight of agency workers. And again, that’s something that comes from immigration enforcement supporting that view. And basically, again, totally weak processes. So when they go in…and you have to remember that when an immigration enforcement team comes in, they’ll be looking not just at the documents, but the systems and controls you put in place to make sure that if you’ve got five HR administrators checking documents. How much training have they had? There’s the difference between each one and can they actually describe what checks they carried out on each document.

Cathryn: Okay, thanks, Tony. And we’re just gonna take a quick break for our second poll now. And what do you regard is the biggest risk of employing an illegal worker?

Just choose one option this time from fines imposed by immigration enforcement, damage to your organization’s reputation, disruption to your organization, or potential fraud.

And Tony, when you’re talking to organizations what are they most worried about when it comes to illegal workers?

Tony: I have to say I think the second one, damage to the reputation because whether it’s a fine which you have to pay or whether there’s disruption, ultimately this gets out and suppliers and clients of theirs you know, are concerns. So I would say that the biggest thing that people are concerned about is their brand and reputation within the market.

Cathryn: Okay, that’s really interesting. So 48% of your…of our audience agree with you there. The percentage was actually rising as you were talking about it so I think you swayed them on that one. And we’ve 39% of people saying that they’re concerned about fines imposed by immigration enforcement. Potential fraud much less of a concern, just 8% of our audience selecting that and just 5% selecting disruption to their organization.

And so Tony’s now gonna go on and talk us through these risk of employing illegal workers.

Tony: Okay, so interesting people, the top one there is clearly the fine. And as you know from the immigration 2016 I’m sorry the Immigration Act 2016, prior to that there was a sliding scale of fines dependent on what level of effort they’ve deemed you’d put in. Now, it’s just a straightforward £20,000 fine per illegal employee and that can be reduced to £15 if people agree to pay to settle early. 

The brackets point to UKVI will fine the deepest pockets comment there it’s actually come from an immigration lawyer who does a lot of these in terms of challenging fines. And basically, this goes back again to the kind of main contractor, subcontractor arrangement or agency. And they will still potentially fine big companies who have got multiple agencies whom they deemed to have the responsibility for right-to-work checks.

And I think now the next couple of risks are the ones that have come in more recently on 2016, so criminal prosecution and prisoner unlimited fines. And that prisoner unlimited fine is actually maybe for a member of staff who clearly has knowingly and has taken on board maybe through some kind of criminal activity illegal employees through the organization. So that is to try and dissuade and stop people from inside dealing and placing probably in terms of slavery etc. However, the criminal prosecutions are there and should be taken very seriously.

As is disqualification as a director. You can see then closure and compliance orders, as of 2016, immigration enforcement can now close a business. It can close a construction site. It can close a factory for an indefinite period of time while it undertakes its investigation and that’s obviously a massive disruption to business. And there are clearly health and safety risks and security risks in terms of employing people you don’t know who they are. And what are the bogus qualifications that they have? We do a lot in the NHS and that’s a very, very major big part of their thinking. It’s not just the right-to-work processes, it is actually what else have they actually lied about.

We’ve talked about reputation commercial damage that’s particularly for things like recruitment agencies or anybody placing staff into other clients. Cleaning companies, for example, where they’re putting their staff into sensitive large and well-known organizations. And more increasingly now they are being asked to evidence what is they are doing to make sure that there’s no brand damage to their clients should there be illegal workers be found on their premises.

And financial cost is obvious. If you are sponsor for future work permits that would be put at risk. And I think probably one that often isn’t thought about is actually as soon as you have an immigration enforcement action or get visited and are on the radar, not only are you going to get more visits from them but the likelihood is that other organizations will get involved looking at your business.

And particularly if you’ve got a number of illegal workers found in your organization. So HMRC, the gangmasters of the Health and Safety, Department for Working Pensions. And ultimately potentially the police could be involved in doing investigations and it’s hugely time-consuming and disruptive elements of your business.

Okay, so this is just now starting to move into why should we potentially move from manual checks into electronic checks?

So on manual checks clearly you want to do things quickly. But you’re only concern, take copies, you’re going after to do some kind of physical, hopefully some physical check out if they’re genuine. You’re gonna have to store all those, you’re gonna have to make sure that you can get access to them for internal and external audits. So it is a little time-consuming, paper-intensive process if you’re actually doing photocopies.

Now, if you’re recruiting one staff, member staff a month that’s the less of an issue. If you’re doing maybe 50 a month across 5 different locations that becomes an administrative challenge, to say the least. So I think manual checking you know, has a place certainly for certain organizations. But as soon as the numbers go up and all the number of low locations go up then that makes it a little bit more of a challenge.

So how can things be made easier? So in terms of thinking about electronic validation which clearly a lot of the people on this webinar are currently not doing, then it’s obviously a step in terms of what benefits does it bring and what considerations do I need to think about? On the one side of this balancing, there’s clearly the risk. What is a risk that you’re trying to mitigate? And in this instance, we’re talking about right-to-work. That is the ability to actually improve my current onboarding process to make it more compliant and reduce the risk of fines and/or brand damage, for example. 

However, and we’ve said it would come back to it, one of the things that’s often forgotten about in terms of fraud is one of the biggest commitments or biggest areas of fraud in business is actually internal fraud. And if you don’t know who the people are that actually you’re employing, then actually you’re gonna have a problem potentially with people committing fraud and disappearing and you have no idea who they are. 

And there’s a very simple example of that. There was a person turned up on a building site with false documentation. He was allowed to work. The next day everybody came in, the container containing all the high-value tools had been broken into, disappeared. And it ended up being this chap they had recruited the day before and nobody knew who he was because he was on fake documentation.

So there’s clearly lots of other impacts, but ultimately number one, right-to-work compliance. And really once you’ve decided what that risk is it’ll dictate to a certain degree your mitigation. By which means I mean, what you want to do to defeat it? And if you’re working in, for example, an accountancy firm, the chances of people working with fake documents is a lot lower than it would be say in a cleaning company. And so, therefore, maybe your view as to what you want to do in terms of level of validation will be different.

Now, on the other side whatever you decide the risk is and what you want to mitigate, you’ve then still got to deploy technology easily. It’s got to be easy to use for your HR team and whether that or your branch managers or your store managers or your restaurant managers, wherever the right-to-work check is carried out it’s got to be easy to use.

It’s got to fit into your existing process, whether that be a centralized share service team that make the final decision, whether that be on the ground at your store, or whether that be in a centralized HR office. And amazingly I can go to three different retailers and each retailer will have a different onboarding process with different authorities at different parts of the organization to make the right-to-work final decision.

There’s clearly a cost implication and then what support you have or would you like? For example, you might just want a piece of technology that tells you the identity document is real or fake. Alternatively, smaller organizations more diverse or geographically spread, the organizations may actually want more support with the right-to-work decision, i.e. getting experts to look at some of the wider documents, not the ID’ing documents. 

And it’s just a balance of these two things really on these two sides that ultimately we spend a lot of time talking to organizations about. And it really could be as simple as you need to use a cloud system which is very simple to deploy, very cost-effective, and actually operationally very easy to deliver.

And we can deploy that within about two hours of an agreement and you can buy 100 cloud scans and that will last you a year because you’re a small organization. On the other end of the spectrum, you may have a very large NHS trust with thousands of people coming through a centralized office. And we may have three or four desktop scanners. And they’re still both doing exactly the same thing for exactly the same reason, but they’ve just got different pressures and influences on those balances.

So really what that will drive you to once you’ve made that assessment is one of three core products. Now, don’t worry about all of the details on the reports on the right-hand side. What I want to really point out on this slide is that there are essentially three platforms. There is what we call the desktop scanner which is the same scanner that you would see in an airport and does the most robust level of validation. So you’ll see just on the report on the right-hand side is ultraviolet, there’s infrared, there is visible light, there’s RFID chip opening capability.

So it is the most robust validation. And it’s really designed for either high-risk organizations so, for example, we have systems in nuclear facilities, where both checking visitors and staff. And they would take nothing other the most high you know, best capability of validating documents.

It is also designed for organizations with very high volumes of applicants coming through a single office. So going back to the NHS trust or local authorities or big factories, for example. And it is a lot more economical, a lot easier to use a single scanner like that than it is to say use a mobile device.

The second platform is the cloud-based solution. And the cloud-based solution is by definition very versatile because you can have lots of people accessing it from lots of different places as long as there’s internet connectivity. However, the validation level is a much lower. It is not got ultraviolet, it hasn’t got infrared and it hasn’t got chip opening because we’re obviously validating an image.

Now, in right-to-work, that’s less of an issue because the quality of fake documents is pretty low. And our analysis which we’ve shared with the home office which has allowed them to rewrite their guidance, is that the cloud-based technology will find around about 85% of fake documents that would be detected by the more robust desktop scanner. So it’s not gonna find a 100%, but it is gonna find considerably…considering more than you would do visibly or by visible inspection. 

And that cloud solution can be accessed by computer, by mobile, by tablet. It’s very versatile so it’s very, very popular in organizations. I’ve got again multiple sites and maybe restaurant chains, for example, this would be a very [inaudible 00:22:13]. They’re not going to put a scanner into every restaurant. What they’re gonna use is mobile, using the cloud technology.

And again that cloud technology gives us the flexibility for adding layering and an awful lot more support, for example, around actually doing managed service around right-to-work checks if the organization wants it. So we will check every document, not just the identity document in some instances to make sure that we can provide a right-to-work report, not just a validation report.

And then lastly, we have the mobile app. And the mobile app is as described. It is downloaded from the App Store onto the device and it is specific to the device. Very popular in facilities management businesses where they are recruiting cleaners say on a Saturday night, internet connectivity may be an issue. And the mobile app allows them there and then to essentially use the video built into the phone to video the document and get an instant decision as to whether the document is real or fake.

Generally, you say a facilities management may have five contract managers, each one will have one of these devices. And can then do everything on the ground and collect all of the other supporting information within the app securely. So three very different platforms used for very different environments and we do have clients that actually have all three. Because they look at their overall organization and decide that actually their factory maybe or their warehouse it needs a desktop scanner. Their head office might be a cloud-based solution, but maybe they’ve got one or two guys compliance officers who are going out and doing checks as well.

So there’s not one, most clients will take one solution, but they say if you’re a more complex organization you could have a combination of all three solutions. So this is really just a little bit more detailed just for those who are maybe interested that essentially this is a report that comes off a desktop scanner.

So the important thing for right-to-work is the top left-hand corner because you’ll notice straight away that it’s actually time-stamped. So you know, this is essentially for this Irish passport this is the right-to-work. Now, this is the document that is produced by the scanner within about 12 seconds of the document being presented. It’s produced automatically, it’s safe to a file location of the clients choice and it is all client-side. There’s nothing that the TrustID has to do with this at all. It is all done by the user on the site.

Now, if you can imagine having an immigration enforcement visit, and at the moment you’ve got photocopies that you’re presenting and trying to explain what checks you carried out. Whereas in this you’re handing this over and saying, “There you go. That’s the level of checking we do.” Which, of course, is very powerful and we know from the evidence is actually means that generally, the immigration enforcement will move on to the next organization because they can see you’re taking things seriously.

And in terms of the checks that it’s doing, I won’t go into too much detail. As I said earlier, you’ve got ultraviolet, infrared, and chip opening capability. But if you looked broadly down the middle, you’ll see there’s a lot of machine-readable zone checks which again, we haven’t got time to go into detail. But we also do an Amberhill check which is the Metropolitan Police’s database of stolen and fraudulently obtained genuine documents. So maybe lots and lots of green ticks but it’s being stolen, we would know about that if it had been reported.

As a quick example of where this makes a big difference, we have deployed a system to a very well-known London venue. And prior to the deployment were getting a visit from immigration for enforcement every six months. They would generally turn up with two wagons. They would spend two days and generally drive off with lots and lots of illegal workers. 

We deployed our system, a single scanner into the location. And on the first visit after the deployment the immigration enforcement turned up, sat there, went through the computer, everything was electronic. They spent half a day rather than two days and walked away with nobody because obviously nobody had been employed illegally because of this system. So in terms of not just stopping illegal working, in terms of making the audits and checking from internal and external organizations, electronic validation is incredibly useful.

And then really I just wanted on this slide, just replace this [inaudible 00:26:50] and see we’ve two minutes to go. And this is really showing you the alternative in terms of cloud. And the point I wanna make here is how, again, how different the validation level is.

And you can see from the image that somebody has just taken a photograph of this. So straight away that photograph essentially has been uploaded through our cloud service. And that report that you’ve seen there will come back most instances as a decent image within about 60 seconds from the image being submitted. So you can take a photograph from a phone, submit it to the browser, through the browser into our service and get a report back like this within 60 seconds. If it hasn’t come back in 60 seconds, generally it might be the quality of the image. In which case, we’ll manually override and we’ll normally send it back within about 20 minutes.

But again, whilst it’s a lower validation, clearly you’ve still got the date stamp who submitted it where. And again, as a report that you can present to any auditor or immigration, it is considerably better than a photocopy. And it shows a level of validation which you simply can’t do visibly or unless you spend probably half an hour on each document which you’re not going to do. And so that’s kind of the, I suppose, the spectrum of validation levels that you can have.

In the last two years since we’ve had the cloud-based, I would say that 60% our client base have moved to cloud. And it is the fastest growing product that we have because it is the most versatile, it is the cheapest generally to deploy as well. And it is the easiest to use because you’re just taking a photograph of a document.

Okay, so in summary, I hope what we’ve done really is a quick run-through and reminder of what you should be doing. Hopefully, everybody understands that and is doing it and really they’re moving through to what happens if it goes wrong? And again hopefully just as a reminder, the risks are there and nobody knows when a visit may or may not happen from immigration enforcement. 

And they certainly have sector-specific areas they focus on. And certainly cleaning, construction, catering they all have had their focus in the last 18 months. Who knows where the next focus will be. And so really you know, just reiterating what the risk might be. And then finally, you know, what is available to mitigate those risks? What does the electronic validation and more I suppose sophisticated rights of work systems bring?

Well, here I think summarizes, you know, essentially reduce the risk to your business both in civil and criminal penalties and brand and internal fraud, which are I still think the principal risk that everybody faces. But more importantly to a certain degree and people forget is that it also brings a lower cost of compliance because you have to do compliance to right-to-work. You have to take copies, you have to give evidence that you’ve done everything that the law requires of you.

So really electronic validation can make that whole process a lot easier, a lot smoother, and a lot less administrative heartache. You know, because it’s electronic you can store the results. There’s no paper copies. It’s quicker than manual inspection, no training requirements when we deploy to Oxford City Council or the immediate benefits. They didn’t have to train. I think they had 80 people across the council that had to be trained on documents and so that just took that away. Clearly, as I say efficient audit and quicker and painful enforcement visit should you ever be unfortunate to have one. 

So really I hope that’s given you, I’m two minutes over because I think we did want to leave a good 15 minutes for questions, I hope that’s given you a good feel for electronic validation and I’ll be happy to take any questions.

Cathryn: Thank you, Tony, for sharing those insights with us. And showing how Trust ID Solutions can help to make right-to-work checks and more simple and more effective. So as Tony, mentioned now we have around 15 minutes for your Q&A. Just send in your questions using the box that you should be able to see on your screen and we’ll try to answer as many as possible. And the good news is you’ve already been sending in questions throughout the presentation which is great.

So and I’ll start off with the first one. Is it the law or best practice that documents have to be checked before an employee’s first day of work?

Tony: Yes, you must check them before they are employed certainly. So if somebody has applied and you’ve done, I don’t know, process remotely in terms of looking in their CV, done the telephone interview and you’ve chosen to employ them. When they turn up for work before they can go on the payroll their documents and must be checked.

Cathryn: Okay, thank you, I hope that answers your question. And we’ve got another one here. Will there ever be any additional checks of birth certificates?

Tony: So birth certificates is a tricky one. If you have a three light scanner the desktop issue…actually you can’t put a birth certificate in that. And there are some UV features that you might be able to see, but most people wouldn’t go that far. So the quick answer is no, you’ve just got to be reasonably diligent in making sure that actually you’ve looked at it and it doesn’t look like it’s a home-produced photocopy.

Cathryn: Okay, great. And do we have to keep paper copies of the documents or will a scanned copy be sufficient?

Tony: Scanned copies are allowed. So if you take a scan and you store that electronically that’s absolutely fine, but yes either paper or scanned are access…are allowable.

Cathryn: Okay, interesting. And do the original documents need to be signed as seen?

Tony: Yes.

Cathryn: Okay, that’s an easy one. So we have a couple of questions which are bit more specific about TrustID solutions. So you mentioned that there’s a mobile app and it showed that it was compatible with iOS and Android. We’ve had someone asking if it’s available on Windows Phone?

Tony: So the app which is where we’re accessing the video to do the immediate validation there and then and not using the internet, the answer is no. But all Windows users, what we suggest is actually as long as internet connector is fine you can do exactly the same on our cloud-based app.

So again, it really depends on the circumstances and where those checks will be carried out. If it’s good internet connectivity you can do it on any phone of any description. But yes, unfortunately, if you’re in a non-internet location and require offline validation, we don’t support Windows at the moment.

Cathryn: Okay, thank you, Does these scanner work with EU identity cards?

Tony: Yes, all our solutions will check EU identity cards. Anything with a machine-readable zone for those who are not familiar with that terminology, if you think about your passport or any identity document you’ve been presented in the course of your work. There is a series of numbers and data and chevron’s, for example, in a passport will be your name and document number that’s called the machine-readable zone. Anything with a machine-readable zone. So that’s any international passport, UK visa, biometric resident permit, EU ID card all have [inaudible 00:34:06] and therefore can all be validated from any of our technologies.

Cathryn: Okay, fantastic. Thank you, for that. And we’ve had a couple of questions around cost for these services. So one person has asked, what are the costs for a cloud-based platform? And we’ve had another attendee ask a bit more specifically, how much would it cost for an organization of around 4,000 people? Can you give us an idea of cost?

Tony: Yeah, so the first broad answer around cloud-based solutions it’s a volume based model. So our prices for just the validation, so we’re not talking about broader right-to-work, so I’ll just keep it simple at this stage. If you just wanna validate the identity documents, our entry price is £2 per scan, if you’re doing anything really less than a thousand checks a year. So we have lots of organizations who phone us up and say, “We’re employing 100 people in a year.” In that case, that’s £200 and you can check everybody and the credits last for two years.

Conversely, the other end of the spectrum, we are dealing with organizations that may do 50,000 checks a year. In which case the price will be probably down to around about 70 P per validation.

Now, in between those, let’s take the 4,000 model. So for 4,000 we’re probably talking around about the £1 50 mark per [inaudible 00:35:25] per check. We offer two ways of doing it. Either you can buy, and there’s more discount, you can either buy your annual volume up front. And so people will come and buy 4,000 checks so say they last for two years. And you’ll get a monthly report from us saying how many you’ve got left and you just simply phone when you need more.

The other way of doing it is actually most of our clients will buy them in batches. So they’ll say, “Well, we’ll do 4,000 but you know, what? We wanted to buy them in batches of 500.” Or buy them in batches of a 1,000 and then just top up as they go.

So your price range will go from probably the cheapest will be 60 P up to £2 entirely based on volume. If you want us to do the full right-to-work managed service and so look at all documents, birth certificates etc., should somebody present without a British passport, a birth certificate and a sort of a NI number.

We’d have to look at everything and you’re really adding 50%. So if you’re a small organization doing and the validation will cost you £2, then really a fully outsource managed right-to-work check with a right-to-work certificate produced from those would be £3. So that’s the kind of the price range we’re talking about.

Cathryn: Okay, fantastic. I hope that helps you, you’ve been asking about prices. We got loads of questions coming in so I’m gonna try and keep to the point on them. Can we use the report to submit as ID verification details with DBS checks?

Tony: Yes.

Cathryn: Okay, that was a nice, simple one.

Tony: If you can and a lot of people so NHS we…I think we’ve got over 100 systems now in the NHS. And obviously, they’re validating the documents for obviously right-to-work. And then many will use those documents if applicable and it’s suitable for the DBS support as well.

Cathryn: Okay. Are we able to check residents documents with these scanners?

Tony: Again if it’s…if we’re talking about biometric resident permit, then the answer is yes because it’s an identity document. So if I’m assuming that’s what they’re asking in terms of residence all visas, we can check yes.

Cathryn: Thank you. Do I have to make right-to-work checks if I only have British employees?

Tony: Yes, now, this is a very important…I’m glad that question has come up. I’ve lost count of how many times I’ve been asked. We are low risk because we have…it’s not normally 100% but high percentage of British and you… The law says you cannot in any way choose, you know, or discriminate between.

So you’ve got to check every document regardless. So if you’re a 100% British and 100% British passports you need to check all those passports. Interestingly, the highest proportion of fake documents we find are British.

Cathryn: But yes, make sure that you’re checking everybody’s documents. It’s really important not to be discriminating as Tony says, so that’s right.

Tony: Yeah. You will be breaking the law on discrimination if you choose to. I had one company who did do exactly that, they were checking only the non-British documents.

Cathryn: Oh, dear, I’ve just made a really screwed up face there, oh, dear. How does the validation process work for visa and work permits?

Tony: So in terms of the validation, so let’s be clear between the validation. We will validate that the BRP or the visa is genuine. What we won’t do on the validation is tell you its time limitation. That is part of the managed service where actually if you wanted us to do that we would then check whether it’s got any time limits or permissions, etc. And then we will notify you and we can also notify you when you need to actually get the person back in to make sure they’ve updated said document.

So there are two levels of service. One is very much telling you it’s a genuine BRP or a genuine visa. And the other part is actually telling you we’ve recognize there’s a time limit on this. And not only we will tell you it’s time limited we will also tell you when you need to actually recheck two different services.

Cathryn: Okay, hope that answers your question. Can employees submit their documents to the service or does it always need to be the employer i.e. the HR team or someone else already employed by the organization?

Tony: Well, given going back right to start that somebody at some point within the organization must see the original, that will much depend on your process. So, for example, there are some organizations that will take copies from the employee, get the employee to send a copy of the document in. And will validate it prior to a final decision being made or maybe before that person being sent to, you know, as an agency to another organization. 

But at some point within that process, somebody must see the original document. Now, it may have been validated with TrustID and a TrustID report may have been sent to the ultimate employer. But, you know, that still has to be married up with the original document at some point.

Cathryn: Okay, I think that…

Tony: I hope that’s clear.

Cathryn: Yeah, I think that is clear and I think it covers a couple of other questions which you had come in. So somebody has asked, can they take ID documents for any candidate who is coming the second interview or should it be offered to the final candidate that’s been selected? Feels to me that that’s the process decision to be made by the employer themselves.

Tony: Correct, and that’s a common one again where to, you know, especially if you’re employing electronic validation. You know, why incur the cost to a certain degree if checking lots and lots of documents, if actually you only have to check really the ones that you are going to employ? But that does depend on my balancing point, that does depend on the current process, and again different people have different processes. So that is a decision for the organization ultimately.

Cathryn: And we have a supplementary question which again I think you’ve already covered. Asking, can we accept the candidate to send the photo and validate it with the cloud-based solution if the employee is remotely based? It feels to me like this is another case where you’ve absolutely got to see the original at some point.

Tony: Yeah, so you can and we do a lot of that. So, we do an awful lot of what I would call remote validation on behalf of clients where they’ve not at that point seen the client or the applicant, I should say. And they want to do all those checks remotely, so a healthcare recruitment business looking to take a doctor as a locum.

But ultimately again, they have to have an arrangement with ultimately their clients or with the applicant. Or somehow that at some point whilst all those checks have been done and recorded, that somebody can also confirm they’ve seen the original documents at some point within the process.

Cathryn: Okay, great. Just to let you all know, we’re about in our final minute of the allotted 45 minutes. We still have a lot of your questions still to answer. So and we’re going to keep running as long as you’re sending in questions. But I mean, not for the rest of the day, but long enough to answer them.

So if you’re time-sensitive and you need to leave the broadcast, that’s fine. All the questions and answers will be covered in the on-demand version that you will get by e-mail tomorrow. If you still have more questions and want to find out the answers to the questions that have already come in, please stay on the line and we’ll do the best to answer them as quickly as we can.

And so we have a couple of questions about the relationship between CIPHR and TrustID. And asking is there an IPO between those two systems? How does information about passports or visa expiry dates get fed from your solutions into CIPHR? Can you upload directly from TrustID’s solutions into CIPHR? Tony, could you explain a little bit about the relationship between the two systems?

Tony: Yeah, so at the moment the answer, the quick answer to that is no, but clearly it’s something we are working with CIPHR on. So theoretically absolutely everything that was just asked, yes, it can happen. So there can be a number of ways of that that actually takes place. It could be built into the CIPHR process where it actually just asks you to upload documents and there’s a straightforward API call to do the validation.

Conversely, it might be a call into to get the user to use a TrustID app to actually do the fully outsourced service because we need the user to ask or answer some questions on the ground. For example, have you seen the original document? Which we can’t do remotely.

So there’s a whole range of different ways that that does it. But the simple answer is, yes, there is an API, yes, it can integrate to CIPHR. I think ultimately, Cathryn, I hate to throw this out, that’s still a decision for CIPHR to take because ultimately the clients are CIPHR clients. But our API is there and we have integrated with other HR systems.

Cathryn: Yeah, I guess from side to side it’s obviously we have a close relationship with TrustID. We’re completely happy to work with them on integrating the two systems. I guess for us it’s a case of when the demand is there we’ll do the integration work and we’ll get that set up for you. So as soon as any of our existing customers or potential customers say, “This is something we definitely want to do,” then the process is in place to make that relationship work.

Tony: And I would add to that, Cathryn. That certainly the other ones we’ve done have been totally driven by client demand rather than system demand because obviously, this has been increasingly hot topic.

Cathryn: Absolutely, and we have a question here, what will happen with the systems you offer following Brexit?

Tony: I wish I knew the answer to that. So those people who don’t know, I am chairman of the Association of Document Validation Professionals. I work a lot with the home office and one of the things that were obviously trying to understand is how right-to-work legislation may or may not change in light of Brexit. At the moment there is no answer, no strike because nobody knows what Brexit it’s going to look like. And so there’s a whole range of answers to that question and all of which are speculative.

I think the one thing I can probably with a high degree of certainty saying is that right-to-work checks will remain. How they will look is probably the one that subjected to man. Either will they be slightly loosened or conversely will they be tightened? Everybody will have seen that the right-to-work legislation or the right-to-work guidance was updated in June of this year. So fairly recently, to take in account of the Windrush scenario plus also the change of rules on Croatian Nationals. And there was no other changes and no inclination of any other changes, you know, about loosening any requirements in fact, quite the opposite there. Things generally seem to be tightening up. But who knows? I’m afraid is the real answer to that.

Cathryn: Well, I think we did very well to get to 45 minutes plus without anybody asking about Brexit. So I think we’ve done quite well there. And we have another question related to DBS checks, this audience member says, “They undertake DBS checks on all of our employees. Often we are supplied with passports, driving licenses, or birth certificates. Will the DBS not pick up any fraudulent documents as is always asked for the document references?”

Tony: So DBS have…do basic because they’re basing it on images so they don’t do document validation per se. They are linked to Amberhill to make sure they’re not stolen documents. I can’t talk for DBS and what they do and don’t do. I do know we’ve been involved in a number of cases where we found fake documents and arrests have been made because they are trying to get sensitive jobs in care. And that’s mainly come through the Amberhill system. 

But clearly, if you are taking the person on the right-to-work check and you want to validate them, then at least you’ve got a high degree of certainty that the document you’re submitting them for DBS is valid. Rather than relying on the DBS to do that because they’re only seeing an image.

Cathryn: Okay, thank you, hope that answers your query. Can the system check right-to-study as well as right-to-work?

Tony: So right-to-work by definition is we’re doing the identity document requirement of that and we do exactly the same for right-to-study. So if you…so we do this for universities. So if you apply to university to study you have to have your identity checked and we do the exactly the same as we do for right-to-work. 

What we’re not doing on the right-to-study is then checking all the other stuff that comes around your requirements. And, you know, have you got sponsorship and you know, all the other things that come which the universities do and understand far better than us. But ultimately universities come to us to make sure that, that passport has been presented is in fact genuine.

Cathryn: Okay, thank you, very much. And another question is, will the system automatically highlight restrictions to work?

Tony: So going back to what we said earlier, the base validation system won’t do that. In fact, we’re just telling you whether the BRP that may have the restrictions on it is genuine. However, we do have a service that will actually look at the document and actually pick up all restrictions and advise you of those restrictions. And also, if those restrictions are, in fact, time limited and whether they need to be reviewed again in three months, for example. But that is the managed service, not just the validation service.

Cathryn: Okay, thank you, very much. If scanning a document how do you sign and date it?

Tony: So as you’ve seen from the examples I gave at the end of the presentation. When you access any of our systems you have to put your username in so we identify who’s actually presented that scan. And therefore, every report that we produced has a date stamp on it. It tells you who took the photograph or who put it on the scanner, i.e. who did the check. And it also tells you exactly when that happened so it’s date stamped as well. 

And you could have other information on there if you wanted. You could have branch based locator, if you wanted it. But most people are happy. The legislation says it has to have the name of the person and who checked it and it has to have when it was checked. And every report we produce has that detail on it.

Cathryn: Okay, that’s brilliant. And can expired British or EU passports be accepted?

Tony: Expired EU and British passports are suitable for right-to-work, but obviously non-EU expired documents are not. And our reports will flag that and our reports will tell you from what we call our flag system, if it’s in date, it’s green. If it’s a British or EU document out-of-date it will not fail, it’ll just be an Amber just to tell you it’s out of date. And if it’s a non-EU document out of date it will be a red cross i.e. failed validation, not because it’s a fake document but because it’s out of date.

Cathryn: Okay, that’s great and there was a supplementary question there. When a British or EU passport or ID card expires, should I be requesting to see a new document?

Tony: There’s no requirement for you to do that, no, because they are allowable documents. But obviously, if it’s an EU document, you know, how they’re travelling outside the country. But if somebody’s been here and it’s just expired and they haven’t got around to doing it, there’s no requirement for you to see a new document. So the document they presented or be out of date, if it’s British or EU you don’t have to re-see a new document.

Cathryn: Okay, fantastic. We have a couple more questions around cost of TrustID solutions, [inaudible 00:50:18]. And what is the cost of a desktop scanner to start with?

Tony: Again, it varies depending on the number of scanners. But if you were to work on an average price of around £1,750 plus VAT per year and because it’s hardware involved and software. It’s a contract that normally runs for three years on that, whereas cloud and mobile it’s different. It’s just, well the clouds just per scan. But the advantage of the desktop system is that it is unlimited scanning. 

So again, going back to the cost and the balance. If you’ve got a single location where you’ve got thousands of applicants coming through a single HR team, then actually £1,750 could be a lot more economical than buying 4,000 cloud checks, for example. So this again goes back to my balancing, what’s your process? Where are these checks being made? How many different people are doing it?

And so really if I look at our online retailer that we’ve got up in the Midlands, they very much have got a desktop scanner in their warehouse because they have a very, very high turnover of staff and number of checks are doing. It’s just you know, it was just easier operationally for them to have a scanner. And yeah, £1,750.

But if you were to buy, some organizations by multiple scanners, they may buy 10 scanners and like all things volume, the price comes down. And I think we’ve got some scanners out there like £1,200 a year because the organization’s got, you know, a high number of units.

Cathryn: Okay, thank you very much. And on the new cloud-based solution somebody just wants to confirm if there were any initial set up cost or whether it was just a charge per right-to-work check?

Tony: Yeah, there are no set up charges for any of our systems. So on the cloud literally once we’ve got agreement on the volume and the price, you sign a license agreement your operational normally within 24 hours. And you can have as many users accessing the system as you wish. There are no user licenses, there are no setup costs. It is just you buy however many hundreds or thousands of scans you want.

Cathryn: Okay, fantastic and what are the costs roughly for a fully managed service? I mean, I imagine this depends very much on what the organization is asking you to manage for them.

Tony: Well, no, as I was saying earlier so the managed service is essentially the full right-to-work service. So we will give you not just a validation report on any identity documents, we will give you a right-to-work report. And that as I said, it’s generally about 50% higher. So if you’re doing anything under a 1,000 checks a year our managed service will be about £3 a right-to-work report. 

If you’re doing, going back to kind of mine, you know, over 50,000, that might be around about the pound, one pound ten depending on the volume. So it’s entirely volume. But it’s about 50% higher than just a standard validation. So yeah, if you’re a small organization, under a 1,000 checks a year, work on £3 and it’s only gonna get cheaper from there.

Cathryn: Okay, that’s great and we have just a couple more questions to tackle. So if you do have any more questions, please send them in now, otherwise, we’ll be ending in a few minutes time. And someone asks, can the system be used in conjunction with the DAVIS License Check system?

Tony: Well, I’ve never had that. Davis? Never heard it.

Cathryn: DAVIS License Check system.

Tony: DAVIS License, I’m afraid I don’t know the answers. I’ve never been asked that question. I’ve never heard of it. DAVIS License Check system, I will go and research that and let you know.

Cathryn: Yeah.

Tony: Our systems can be…can operate and do operate across multiple different systems, you know, whether that be an API or not. But if that’s a driving license system, I don’t know, but I’ll look into it and get back to you.

Cathryn: Okay, thank you. And does the check capture employee consent for the check? So I guess that’s around GDPR.

Tony: Yeah, okay, I get that. So the answer to that is not specifically. So nobody has to ask permission to do these checks. And I think it’s a misunderstood kind of concept and I know everybody’s excited about GDPR. You are required by law to do the check, okay, so by definition you have to take the document, the identity document over. Except that you don’t have to ask permission because you’re required to do it by law.

So in the same way that if you ask a person for their passports or a copy for proof of the right-to-work, you don’t have to ask their permission to do that. It’s a requirement for you to do it by the law. So there’s no requirement for consent.

Cathryn: Okay, thank you, and we’re on to our last question…oh, yeah, last but one question. It was the last question, then another one sneaked in. Does the app prevent you from validating a photocopy of a passport or ID card?

Tony: So yeah, the quick answer to that is no, depending on what you do. So ultimately, we do get asked, can we go back and do retrospective checking on existing scans? So, for example, we did this recently for a big healthcare recruitment agency. They had a load of documents. And they wanted to make sure to some level they were all genuine and we did a retrospective. So you can use technology to go back so there’s nothing in there to stop a person. 

But obviously, this goes back to who is submitting the document. So if this is a potential employee submitting a document, you’ve got to be you know, a lot more aware of the risk. They might have submitted something that is a copy of a friend’s document. And this is why the law is the way it is that at some point you must see the genuine. But we can validate copies.

Cathryn: Okay, great and our very final question is about the relationship between your solutions and CIPHR. If there was an integration between the two, where would the scanned document be stored? Would it be in your solution or in CIPHR? And would we need to manually upload it into CIPHR if it’s within TrustIDs solution?

Tony: No, so very simple, it would always be stored in CIPHR and there would be no manual intervention. It would simply be a call upon, you know, at some point within the CIPHR process. It will ask you to submit or upload right-to-work evidence documents. If there’s an identity document contained within that, for example, then there would be a call on through the API. And we’d send a validation report back to sit in exactly the same place. So rather than having a photocopy of the document, you then have a TrustID report.

If however, there was a requirement for the user to do a little bit more, i.e. answer some questions because it’s a managed service. Have you seen the original document? For example, then that would then be essentially a call from CIPHR into our system. The user would do everything they were required to do in our system, but then the PDF report generated will still populate back into CIPHR. So the start and end point will end up being in CIPHR. What happens in between can vary from client to client.

Cathryn: Okay. Thank you, so much, Tony. And thank you, everybody, for being so engaged and asking us so many brilliant questions. And thank you, Tony, for doing you’re level best to answer them all because I realized that was quite a lot of questions to get through. And that is all we have time today. Sorry for running over, but I hope that it’s been worth your while.

If you have any additional questions off the back of the webinar, drop us a line to Or if you are a CIPHR customer please contact your account manager and we’ll do our best to get back to you as soon as we can.

So thank you, for joining us today. Thank you, Tony, from TrustID for sharing your expertise. If you would like to find out more about CIPHR’s HR recruitment solutions or how TrustID can help you with right-to-work checks, just check the relevant option on-screen as you exit here to say that you want to find out more. We hope to see you at another CIPHR webinar soon. Goodbye.

Cathryn Newbery from CIPHR and Tony Machin from Trust ID discuss the pitfalls of manual right to work checks, and how electronic validation could improve your compliance. 

If you’d like more information about CIPHR, email If you’d like more information about TrustID, email

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